Comment on FR Doc # 2013-02408

GSA is voicing a relatively complex cluster of questions that, ultimately, have a single, cohesive answer: Use LEED as intended, as a continuum of the New Construction family (NC, CS, CI, HealthCare, Laboratories, and the rest of the systems governing 'new construction') linked integrally with Existing Buildings: Operations and Maintenance. We recommend doing this with emphasis on selected credits (treated as 'prerequisites,' as you suggest in one of the questions) for energy and water resource performance attainment, metering, monitoring and management effectiveness. By requiring highest attainment in all the requisite EA and WE credits, adjusted where energy costs are low enough to distort results, to emphasize energy savings, instead of just energy cost savings. By requiring fundamental and enhanced commissioning closely integrated with measurement & verification, both thoroughly integrated into the design process, then the resulting performance level can be credibly verified through 'whole-building simulation' (modeling) rigorously verified by metering and by utility bills. These followup processes will create a 'whole building' vision, to enable management to know the unanticipated effects of, for example, green cleaning crews that operate in the middle of the night, keeping lights on much longer than needed. This might not show up in any other LEED database. The certification system used is an experiment, in a real way. Only LEED, in my investigations, affords the breadth and depth of other environmental certifications to allow robust analysis and conclusions to be drawn. Living Buildings Challenge is marvelous, but it is so difficult that many sites and many ways of building will not register. Green Globes cannot be relied on to reflect accurately the materials derivation of products, much less expand to greater and greater degree of reflection of the corporate ethics and science of product derivations. Only LEED has these capacities.